Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Validity of SCN - mandatory requirement of pre-show cause notice consultation - W.E.F 15.10.2020 i.e., after the impugned SCN was issued, Rule 142(1A) has undergone a change, inasmuch as the word ‘shall’ has been replaced with ‘may’. - pre-show cause notice consultation was mandatory under the unamended Rule 142(1A) - A voluntary statement cannot substitute a statutory notice, which is contemplated under Rule 142(1A) of the 2017 Rules - impugned show cause notice dated 21.05.2020 is set aside - HC
Validity of SCN - mandatory requirement of pre-show cause notice consultation - W.E.F 15.10.2020 i.e., after the impugned SCN was issued, Rule 142(1A) has undergone a change, inasmuch as the word ‘shall’ has been replaced with ‘may’. - pre-show cause notice consultation was mandatory under the unamended Rule 142(1A) - A voluntary statement cannot substitute a statutory notice, which is contemplated under Rule 142(1A) of the 2017 Rules - impugned show cause notice dated 21.05.2020 is set aside - HC
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